Mallett v. Labor and Industry Review Commission

CourtDistrict Court, E.D. Wisconsin
DecidedOctober 7, 2025
Docket2:25-cv-01388
StatusUnknown

This text of Mallett v. Labor and Industry Review Commission (Mallett v. Labor and Industry Review Commission) is published on Counsel Stack Legal Research, covering District Court, E.D. Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mallett v. Labor and Industry Review Commission, (E.D. Wis. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

GREGORY C MALLETT,

Plaintiff, Case No. 25-cv-1388-bhl v.

LABOR AND INDUSTRY REVIEW COMMISSION, WORK INJURY SUPPLEMENT BENEFITS FUND and BRIGGS & STRATTON CORPORATION,

Defendants. ______________________________________________________________________________

SCREENING ORDER ______________________________________________________________________________ On September 10, 2025, Gregory Mallet, proceeding without an attorney, filed a complaint alleging that his former employer, Briggs & Stratton Corporation (Briggs), along with the Wisconsin Labor and Industry Review Commission (LIRC) and the Wisconsin Work Injury Supplement [sic] Benefits Fund (WISBF), violated his due process and equal protection rights during the lengthy adjudications of his multiple efforts to secure worker’s compensation benefits. (ECF No. 1.) Mallett has also filed a motion to proceed without prepayment of the filing fee, or in forma pauperis (IFP), and a motion for appointment of counsel. (ECF Nos. 2 & 3.) The matter is before the Court for consideration of Mallett’s IFP motion and his motion for appointment of counsel, and for the screening of his complaint. IFP MOTION The Court has authority to allow a plaintiff to proceed IFP upon the submission of an affidavit that identifies the plaintiff’s assets and allows the Court to find that the plaintiff is unable to pay the filing fee. See 28 U.S.C. §1915(a)(1). Mallett’s IFP application includes information about his finances and is signed under penalty of perjury, satisfying the first IFP requirement. See id.; (ECF No. 2 at 2.). He represents that his monthly gross wages are $3,600, and that he receives $996 per month in social security payments. (ECF No. 2 at 1.) He reports $700 in monthly household expenses, $490 per month in credit card payments, $2,200 per month in 401(k) contributions, and $300 per month property tax payments. (Id. at 2–3.) He reports owning a home with an approximate value of $164,000, an automobile worth $3,600, approximately $21,000 in his 401(k) fund, and $11,000 in stocks. (Id. at 3–4.) While a plaintiff need not show that he is totally destitute to establish indigence, Zaun v. Dobbin, 628 F.2d 990, 993 (7th Cir. 1980), the Court’s authority to grant IFP motions “is reserved to the many truly impoverished litigants who . . . would remain without legal remedy if such privilege were not afforded to them,” Brewster v. N. Am. Van Lines, Inc., 461 F.2d 649, 651 (7th Cir. 1972). Mallett’s monthly income puts him outside the “truly impoverished” litigants for whom IFP status is intended. MOTION TO APPOINT COUNSEL Mallett asks the Court appoint counsel to represent him. As an initial matter, Mallett has no right to appointed counsel in a civil case. See Ray v. Wexford Health Sources, Inc., 706 F.3d 864, 866–67 (7th Cir. 2013). At most, the Court has discretion to try to recruit a volunteer lawyer to help him pursue his civil lawsuit, but only if he shows he cannot afford to hire counsel. See Navejar v. Iyiola, 718 F.3d 692, 696 (7th Cir. 2013); 28 U.S.C. §1915(e)(1); Ray, 706 F.3d at 866– 67 (7th Cir. 2013). “[D]eciding whether to recruit counsel ‘is a difficult decision: Almost everyone would benefit from having a lawyer, but there are too many indigent litigants and too few lawyers willing and able to volunteer for these cases.’” Henderson v. Ghosh, 755 F.3d 559, 564 (7th Cir. 2014) (quoting Olson v. Morgan, 750 F.3d 708, 711 (7th Cir. 2014)). In exercising its discretion, the Court must consider two things: “(1) ‘has the indigent plaintiff made a reasonable attempt to obtain counsel or been effectively precluded from doing so,’ and (2) ‘given the difficulty of the case, does the plaintiff appear competent to litigate it himself?’” Pennewell v. Parish, 923 F.3d 486, 490 (7th Cir. 2019) (quoting Pruitt v. Mote, 503 F.3d 647, 653 (7th Cir. 2007)). Mallett does not assert that he has made any attempt to find counsel on his own. His motion could be denied on this basis alone. In addition, Mallett’s income, as described in his IFP application, indicates that he is not indigent within the meaning of the IFP statute. (ECF No. 2.) For both reasons, the Court will deny Mallett’s motion for appointment of counsel. ALLEGATIONS Mallett’s allegations relate to prior state court adjudications of his efforts to secure worker’s compensation benefits for injuries he sustained more than forty years ago. He alleges he sustained work related injuries while employed by Briggs & Stratton in 1981, 1983, and 1984. (ECF No. 1 ¶7.) Mallet brought multiple worker’s compensation claims for these injuries at the time they occurred, but his claims were rejected by administrative law judges (ALJs) and these rejections were affirmed on appeal to the LIRC. (ECF No. 1-1 ¶3.) Mallett sought judicial review of the LIRC decisions in state court, but the courts also rejected his claims and affirmed the LIRC’s orders. (Id. ¶4 (citing Mallet v. LIRC, No. 85-0929, unpublished slip op. at 1-2 (Wis. Ct. App. Jan. 10, 1986)).) Mallett made further efforts to secured worker’s compensation benefits in 1987 and 2007. (Id. ¶6.) On both occasions, ALJs rejected his claims, and the LIRC affirmed those rulings. (Id.) Mallett sought judicial review, but the state courts declined to grant him relief. (Id.) Mallett then filed yet another worker’s compensation claim in 2014. (Id. ¶10.) This claim alleged that his work from January to April 1984 had aggravated a spinal condition. (Id.) The ALJ denied this claim and the LIRC upheld the ruling for multiple reasons. (Id. ¶11.) This time, Mallett was partially successful in obtaining judicial review, and the circuit court remanded his case back to the LIRC “‘for additional findings regarding the sufficiency of Mallet[t]’s medical evidence relating to his work exposures from January to April 1984[.]’” (Id. ¶12.) On remand, the parties elected to conduct a review of the record from the previous hearing. (Id. ¶13.) At rehearing, the LIRC again denied Mallett’s claim and Mallett again sought judicial review of the LIRC’s decision. (Id. ¶¶14–15.) This time, tThe circuit court and Wisconsin Court of Appeals affirmed the LIRC’s decision. (Id. ¶¶19–23.) On appeal, Mallett challenged the LIRC’s findings of fact, asserted that the LIRC perpetuated fraud by omitting documents from the record, and argued that a purported conflict of interest (the Wisconsin Department of Justice representing both the LIRC and the WISBF as respondents) violated his due process rights. (Id. ¶¶18–22, 23.) Mallett’s arguments were all rejected by the Wisconsin Court of Appeals on June 28, 2022. (Id. ¶¶18–24.) The Wisconsin Supreme Court declined to hear his case on October 11, 2022. (Id.

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Mallett v. Labor and Industry Review Commission, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mallett-v-labor-and-industry-review-commission-wied-2025.